Privacy Policy —
hbo09 Online Betting Platform

Introduction & Scope

This Privacy Policy ("Policy") is issued by the operator of hbo09, the online betting and gaming platform accessible at https://hbo09.cam ("Platform", "we", "us", "our"). It governs how we collect, use, store, share, and protect personal data provided by or generated about individuals who visit, register on, or interact with the Platform ("you", "Player", "Data Subject").

hbo09 operates primarily for the benefit of players in Indonesia who prefer an English-language international gaming experience. This Policy is written in English and takes precedence over any translated summary. It should be read alongside our Terms & Conditions and our Responsible Gaming Policy, both of which incorporate this Policy by reference.

By accessing the Platform, creating an account, or making a deposit, you acknowledge that you have read and understood this Policy and consent to the collection and processing of your personal data as described herein. If you do not agree with any part of this Policy, you must discontinue use of the Platform.

Definitions

For the purposes of this Policy, the following definitions apply:

Data We Collect

hbo09 collects Personal Data in the following categories. We apply the principle of data minimisation throughout — we collect only what is genuinely necessary for the stated purpose.

We do not intentionally collect sensitive personal data such as racial or ethnic origin, political opinions, religious beliefs, biometric data (beyond the ID selfie required for KYC), or health data, unless you voluntarily disclose such information in the context of a responsible gaming support request.

How We Collect Data

We collect Personal Data through the following means:

• Direct submission: Information you provide when registering an account, completing KYC, making a deposit or withdrawal request, contacting support, or participating in a promotion.
• Automated technologies: Cookies, web beacons, pixel tags, and server logs that automatically record Technical Data and Usage Data when you access the Platform. See Section 9 for full details on our Cookie practices.
• Third-party verification services: Identity verification providers and fraud-detection partners may supply us with data points that help confirm your identity or flag suspicious activity. These providers act as Data Processors under written agreements with hbo09.
• Payment service providers: When you initiate a deposit or withdrawal via a local bank or e-wallet, the relevant payment service provider transmits a transaction reference and confirmation status to hbo09. We do not receive your full bank login credentials.
• Responsible gaming organisations: If you have registered with an external self-exclusion scheme, that scheme may share your registration status with us as part of our responsible gaming obligations.

Purposes & Legal Basis for Processing

hbo09 processes your Personal Data for the following purposes. For each purpose, we identify the legal basis on which we rely:

• Account creation and management — to register your account, authenticate your login, and manage your account settings. Legal basis: performance of a contract.
• KYC and age verification — to verify that you are at least 21 years of age and to comply with our anti-money-laundering (AML) obligations. Legal basis: legal obligation and legitimate interests.
• Processing deposits and withdrawals — to credit funds to your account balance and remit winnings to your nominated bank account or e-wallet. Legal basis: performance of a contract.
• Customer support — to respond to your queries, complaints, and disputes in a timely and accurate manner. Legal basis: performance of a contract.
• Fraud prevention and security — to detect, investigate, and prevent fraudulent transactions, money laundering, multiple-account abuse, and other prohibited conduct. Legal basis: legal obligation and legitimate interests.
• Responsible gaming monitoring — to enforce deposit limits, loss limits, session timers, and self-exclusion settings, and to identify patterns that may indicate problem gambling. Legal basis: legal obligation and legitimate interests.
• Platform improvement — to analyse Usage Data and Technical Data in aggregated, anonymised form in order to enhance platform performance, game selection, and user experience. Legal basis: legitimate interests.
• Marketing communications — to send you promotional offers, bonus notifications, and seasonal campaign messages (e.g., Idul Fitri reload bonuses, BRI Liga 1 free-bet promotions) by email or WhatsApp where you have provided consent or where we have an existing relationship. Legal basis: consent or legitimate interests. You may opt out of marketing communications at any time by contacting support.
• Legal compliance — to comply with applicable laws, court orders, regulatory requests, and our international gaming licence obligations. Legal basis: legal obligation.

Where we rely on legitimate interests as our legal basis, we have assessed that those interests are not overridden by your rights and freedoms. You may request details of that balancing assessment by contacting us at the address in Section 15.

Data Sharing & Disclosure

hbo09 does not sell, rent, or trade your Personal Data to third parties for their own marketing purposes. We share your data only in the following limited circumstances:

• Service providers (Data Processors): We engage carefully selected third-party vendors to provide services on our behalf — including KYC verification, payment processing, fraud detection, IT infrastructure, and customer support tooling. These vendors are bound by data processing agreements that restrict their use of your data to the specific service they provide.
• Payment partners: To execute deposits and withdrawals, we must share relevant transaction references with your nominated bank (BCA, BRI, BNI, Mandiri, CIMB Niaga, OCBC NISP, BSI, or Bank Permata) or e-wallet provider (OVO, DANA, GoPay, ShopeePay, LinkAja).
• Gaming content providers: Game studios such as Pragmatic Play, Evolution Gaming, NetEnt, Microgaming, Spribe, and Pocket Games Soft may receive a pseudonymous player identifier and game session data necessary to deliver their game content and to calculate outcomes.
• Regulatory and law enforcement authorities: We will disclose Personal Data to government bodies, regulators, or law enforcement agencies where we are required to do so by law, court order, or regulatory directive — for example, in connection with an AML investigation or a judicial proceeding.
• Professional advisers: Our lawyers, auditors, and insurers may access your Personal Data on a strictly need-to-know basis and are bound by professional confidentiality obligations.
• Business transfers: In the event of a merger, acquisition, or sale of all or substantially all of hbo09's assets, your Personal Data may be transferred to the acquiring entity, subject to equivalent data protection commitments.

In every case of data sharing, hbo09 takes reasonable contractual and technical measures to ensure that recipient parties handle your data with appropriate care.

International Data Transfers

hbo09 is an internationally operated platform. Personal Data collected from players in Indonesia may be transferred to, stored on, or processed by servers or Data Processors located outside Indonesia. Where such transfers occur, hbo09 takes steps to ensure that an adequate level of protection is maintained, including through:

• Entering into standard contractual clauses or equivalent transfer mechanisms with Data Processors in the receiving jurisdiction.
• Transferring data only to jurisdictions that maintain data protection standards recognised as adequate under our operational legal framework.
• Applying technical security measures (encryption, access controls) that travel with the data regardless of where it is stored.

By using the Platform, you acknowledge and consent to the transfer of your Personal Data to our international infrastructure. If you have questions about specific transfer mechanisms in place, contact us at the address in Section 15.

Data Retention

hbo09 retains your Personal Data for as long as your account is active and for a period thereafter as required by applicable law and our licensing obligations. Specific retention periods include:

• Account and Identity Data: Retained for the duration of the account relationship and for a minimum of five (5) years after account closure, in line with standard AML record-keeping requirements.
• Transaction Data: Retained for a minimum of five (5) years from the date of the transaction, or longer if required for an ongoing investigation or legal proceedings.
• KYC Documents: Retained for a minimum of five (5) years after the KYC verification was completed or after account closure, whichever is later.
• Communications Data: Support ticket transcripts and correspondence are retained for three (3) years from the date of the last communication.
• Technical and Usage Data: Aggregated and anonymised after twelve (12) months. Identifiable Technical Data (e.g., IP address logs) is deleted or anonymised within twelve months unless required for an ongoing security or fraud investigation.
• Marketing consent records: Retained for the period of the account relationship and for three (3) years after the last marketing communication, to demonstrate compliance with consent obligations.

When Personal Data is no longer required for any legitimate purpose, we securely delete or irreversibly anonymise it. Deletion requests submitted by Players are handled as described in Section 12, subject to our legal retention obligations.

Cookies & Tracking Technologies

hbo09 uses cookies and similar tracking technologies to deliver and improve the Platform experience. The categories of cookies we deploy are:

• Strictly necessary cookies: Required for the Platform to function. These include session authentication cookies, CSRF protection tokens, and load-balancing cookies. These cannot be disabled without breaking Platform functionality.
• Performance and analytics cookies: Collect anonymised data about how Players navigate the Platform — which pages are visited most often, how long sessions last, and where errors occur. This data is used solely to improve Platform performance and is not linked to your identity.
• Functional cookies: Remember your preferences — such as your preferred language setting, last-visited game lobby, and responsible gaming settings display — so you do not need to re-enter them each session.
• Fraud-detection cookies: Help us identify suspicious login patterns, detect bots, and flag potentially fraudulent transactions by building a device fingerprint. These are used exclusively for security purposes.

You can manage cookie preferences through your browser settings. Disabling certain cookies may affect the functionality of the Platform. hbo09 does not use third-party advertising cookies or cross-site tracking technologies.

Children's Privacy

hbo09 enforces a strict 21+ age restriction. The Platform is not directed at, and does not knowingly collect Personal Data from, individuals under 21 years of age. During the registration and KYC process, we take active steps to verify that every player meets the minimum age requirement.

If we become aware that Personal Data has been collected from a person under 21, we will immediately close the associated account, delete or anonymise all related Personal Data, and withhold any Balance in accordance with our Terms & Conditions. If you believe that a minor has registered an account on hbo09, please notify us immediately at [email protected].

Security Measures

hbo09 implements a layered security architecture to protect your Personal Data against unauthorised access, alteration, disclosure, or destruction. Our key security controls include:

• 256-bit SSL/TLS encryption for all data transmitted between your device and our servers.
• Encryption at rest for sensitive data fields including identity document scans, bank account numbers, and password hashes (using bcrypt with a high cost factor).
• Role-based access control (RBAC) ensuring that staff can access only the Personal Data necessary for their specific job function, governed by the principle of least privilege.
• Multi-factor authentication (MFA) for all internal system access by hbo09 staff and third-party vendor personnel.
• Regular penetration testing and vulnerability scanning conducted by qualified independent security professionals.
• Incident response plan with defined escalation procedures for data security incidents. In the event of a breach that is likely to result in risk to your rights or freedoms, we will notify affected Players without undue delay.

While we employ industry-standard security measures, no online platform can guarantee absolute security. You are responsible for maintaining the confidentiality of your account credentials and for notifying hbo09 promptly if you suspect that your account has been compromised.

Your Rights as a Data Subject

Subject to applicable law and our legal retention obligations, you hold the following rights with respect to your Personal Data held by hbo09. To exercise any of these rights, contact us using the details in Section 15:

• Right of access: You may request a copy of all Personal Data we hold about you, along with information about how it is processed.
• Right to rectification: You may request that inaccurate or incomplete Personal Data be corrected or updated. For certain data fields (e.g., name, date of birth), updated KYC documentation may be required.
• Right to erasure ("right to be forgotten"): You may request deletion of your Personal Data where it is no longer necessary for the purposes for which it was collected, subject to our legal retention obligations (see Section 8). We cannot delete data that we are legally required to retain.
• Right to restriction of processing: You may request that we restrict processing of your Personal Data while a correction or objection request is being resolved.
• Right to data portability: You may request a machine-readable copy of the Personal Data you have provided to us directly, to facilitate transfer to another service.
• Right to object: You may object to processing based on legitimate interests, including profiling for responsible gaming purposes, where you believe your particular circumstances outweigh our legitimate interests.
• Right to withdraw consent: Where processing is based on your consent (e.g., marketing communications), you may withdraw that consent at any time without affecting the lawfulness of prior processing.

hbo09 will acknowledge all rights requests within 24 hours (WIB) and aims to respond substantively within 30 calendar days. Complex requests may require up to 90 days, in which case we will notify you of the extension and the reason for it. We do not charge a fee for exercising your rights unless a request is manifestly unfounded or excessive.

Third-Party Links

The Platform may contain references or hyperlinks to third-party websites, game providers, or payment service portals. Once you navigate away from hbo09, this Privacy Policy no longer applies. hbo09 is not responsible for the privacy practices or content of external websites. We encourage you to review the privacy policy of any third-party site you visit.

Note that game studios such as Pragmatic Play, Evolution Gaming, Spribe, and Pocket Games Soft operate their own game clients that may load within the Platform interface. These studios receive pseudonymised session data as described in Section 6 but are bound by their own data protection obligations and hbo09's vendor agreements.

Changes to This Privacy Policy

hbo09 reserves the right to update this Privacy Policy at any time to reflect changes in our data practices, Platform functionality, or applicable legal requirements. When material changes are made, we will post a prominent notice on the Platform and, where practicable, notify you by email to the address registered on your account. The updated Policy will take effect seven (7) days after the notice is posted, or immediately where required by law.

Your continued use of the Platform after the effective date of any update constitutes acceptance of the revised Policy. If you do not agree with the revised Policy, you must cease using the Platform and may request deletion of your Personal Data as described in Section 12, subject to our legal retention obligations.

We recommend bookmarking this page and reviewing it periodically. The "Last Updated" date at the top of this Policy always reflects the date on which the most recent revision came into effect.

Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or the handling of your Personal Data, please contact the hbo09 Data Protection team through any of the following channels. All correspondence regarding data protection matters should be submitted in English to ensure accurate and timely handling:

• Email: [email protected]
• WhatsApp: +62 811 0000 0909
• Live Chat: Available 24/7 directly on the Platform

When submitting a data subject rights request (Section 12), please include your full registered name, the email address associated with your hbo09 account, a clear description of your request, and, where applicable, a copy of your government-issued ID to allow us to verify your identity before processing the request. This is a security measure to ensure that Personal Data is not disclosed to anyone who is not entitled to receive it.

hbo09 targets an initial acknowledgement of all data protection queries within 24 hours (Western Indonesia Time, WIB / UTC+7) and a substantive response within 30 calendar days.